Circle is encouraging the Securities and Exchange Commission (SEC) to maintain technology neutrality and to clarify the treatment of different permissionless network structures as the regulator finalizes its proposed Regulation Crypto Assets.

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Circle, a provider of blockchain infrastructure, digital assets and applications, submitted these and other comments to the SEC on Oct. 20, the company said in a Wednesday (Oct. 28) blog post.

“This framework should accommodate permissionless institutional networks utilizing permissioned validators (i.e., an auditable set of known validators,) such as the Arc Network by Circle, as infrastructure for issuing, transferring and settling covered crypto assets,” Circle said in its comments. “Known validators provide additional security and functionality while retaining the permissionless nature of the blockchain.”

Circle also recommended in its comments that the SEC ensure that Regulation Crypto Assets operates consistently with the GENIUS Act, clarify the treatment for how GENIUS-compliant payment stablecoins may be used for consideration and settlement assets in capital formation, clarify that qualifying payment stablecoins qualify for appropriate accounting and customer-reserve treatment, reduce the current 2% broker-dealer haircut to zero for GENIUS-compliant payment stablecoins and clarify that technical services performed after a network becomes functional do not constitute essential managerial efforts, according to the post.

“Circle supports the Commission’s effort to create clear, technology-neutral rules for onchain capital formation,” Circle said in the letter.

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